With a more compliance cognizant society, covering assets in regards to OSHA and other regulatory agencies is a concern for many construction organizations. As documenting every aspect required can be a difficult, technology can drastically reduce the potential for error and help streamline work processes. First identify employer responsibilities, then consider available tech options for a more efficient jobsite and organization.
EMPLOYER DOCUMENTATION RESPONSIBILITIES
Employer responsibilities and documentation required include:
- Creating and providing a workplace free from hazards and comply with OSH Act by creating a corporate and job-specific health and safety manual which describes policies and controls for particular hazards;
- Examining workplace conditions to ensure a hazard-free environment, commonly documented through weekly inspections and corrective action forms;
- Ensuring employees maintain equipment, and documenting daily/prior to use and annual inspections;
- Providing safety training in a language workers can understand through jobsite orientations, OSHA 10 certifications and other general safety training as described in the OSHA 1926 standard;
- Ensuring employees are trained and can operate equipment, documented through certificates of training, sign-in sheets, toolbox talks and online learning management systems;
- Properly labeling, posting and warning employees of potential hazards, documented through HAZCOM manuals, color-coded stickers and physical signs near different hazards and zones;
- Establishing and updating operating procedures for a safe environment, documented through the use of Job Hazard Analysis/Job Safety Analysis on the jobsite and through the health and safety manuals overall;
- Providing and training with a hazard communication manual/plan with any and all chemicals associated with the line of work, commonly documented through an orientation;
- Keeping and allowing access to medical, fit tests, blood tests, etc. for all personnel relating to work performed, documented through chain of custody and medical review documents;
- Keeping and posting OSHA injury and illness logs Forms 300, 300a, and 301; and
- Displaying OSHA poster with state and federal rights for employees in a prominent area.
With each responsibility there are multiple ways that technology can provide assistance in maintaining documentation and streamline the process. The employer or compliance officer must assess the needs and wants of the individual company. What might be right for one organization might not be right for another based on size, type of work and capabilities of the jobsite crews (superintendents, foremen, etc.). A fully integrated environmental, health and safety management system is great for some, but may be too excessive for other organizations.
SIMPLE TECHNOLOGY INVESTMENT OPTIONS
There are multiple apps, software and collaborative tools to easily communicate and document an employers’ requirements. Some low-tech and low-cost options are combining a PDF form creator and a shared file folder system. The most common PDF form creators, Adobe and Bluebeam, have both computer and mobile applications that can very quickly be utilized in the field and the technology barrier is pretty low. This, in combination with a shared folder system from an internal server or using a subscription service like OneDrive, Box, Dropbox, Google Drive, etc., could allow for the files to be accessed and shared by company, job or employee.
As this can offer some “real-time” insight, the limitations are in the way the data is stored. It also requires a decent amount of set up with someone that understands how the forms should be created and shared throughout the company. A limitation to this approach is the ability to quickly compare documents, add reminders, set tasks or look at overall analytics, but the information is at least accessible. This type of system is good for items that do not change often, like corporate health and safety manuals, HAZCOM manuals and Safety Data Sheets (SDS). Smaller organizations that may not have the budget or in house technological expertise may prefer an approach like this as well.
BETTER TECHNOLOGY INVESTMENT OPTIONS
As workers become more familiar with technology, integrated or data driven applications make more business sense for organizations as they will help streamline information and offer better productivity with the currently shrinking skilled workforce. Web-based technology for safety data sheets, training documentation, inspection reports and injury and illness data have been proven to save companies money in the long run as described by various case studies and testimonials available online.
Online applications for safety data sheets allow for the research to be completed quite easily and new versions of the SDS updated automatically. They also provide easy binder options that can quickly make the job-specific manual needed under federal law. Lastly, they provide quick and easy access by a search or click of a button, which proves useful in an emergency.
Web-based training management applications (which are often combined with a learning management system) provide relatively easy access to all information on a specific employee in the case of an inspection. They also provide reporting functions that quickly identify what training requirements are needed and have been met for an employee, location or department. Automated reminders of expiration notices assist administrators and trainers in quickly recognizing which classes and people are most important that particular month or quarter. More sophisticated systems also provide the content for training and can allow for real-time access through QR Codes, Magnetic Strips and NFC/RFID devices.
Inspections are a must in construction and a good inspection app not only proves compliance, but also provides real data to help understand common issues and corrective actions needed for the job. Good inspection applications allow for information to be tagged to projects, superintendents and categories to allow for analytics on common trends. More advanced applications provide predictive trends and analysis to help decision makers quickly identify issues and also make policy changes to better eliminate the problem.
As an annual requirement, OSHA injury and illness data must be submitted, so a system to track those incidences can also prove beneficial. Similar to inspection applications, the data is more important long term than just completing the check box and filing the form. A good application should provide compliance as well as streamline documentation for workers compensation claims and safety reporting.
As each individual application may be top of the line in its category, the need for multiple logins and education barriers may pose a problem for some organizations unless the options have APIs or ways to integrate with other systems. If not, this would lead an organization to a fully integrated approach.
HIGH TECH INVESTMENT OPTIONS
The most integrated and expensive option is a fully functioning environmental, health and safety management system which may or may not be tied to an enterprise resource planning (ERP) system. Although it may have the largest price tag, it may be cheaper than having 10 different systems in the previous example. Bigger organizations tend to go down this path, which offers one vendor, one system and one larger investment, but the payoff may be huge if it completely automates a company’s processes. The common argument is that the system is so large, that while it does everything, it does not do everything well. This also requires a much longer commitment and a longer implementation process. The high-tech benefits though can be endless. If all data is synced and the technology provides deeper insight, one could assume that all stakeholders’ needs could be met and automated processes should make everyone’s lives easier.
In the end, not all options are best for each organization, and in some cases a combination may be the correct fit. The key is not necessarily how the employer responsibility is met, but that it is met. OSHA cannot criticize the means and methods, just the results. Take a look at company processes, think lean and develop, or have someone assist in developing, a return on investment for each technology purchase. The end result should be a better, more efficient jobsite and organization that uses technology to provide exceptional service to the end user, the owner.
Brent Sexton. Reprinted from ConstructionExec.com, June 21, 2018, a publication of Associated Builders and Contractors. Copyright 2018. All rights reserved.